Recommended actions
The EAA will apply from 28 June 2025, with a transitional period for limited scenarios. Given the lead time for implementing technology changes, we are already helping our clients prepare to ensure compliance with the law. In particular, we recommend:
- Analyzing which of your products and services are in scope
- Assessing current accessibility levels for both physical products and digital interfaces
- Updating e-commerce platforms and websites both with respect to their functionality (e.g., adhering to WCAG standards), and the inclusion of accessibility disclosures
- Updating self-service and payment terminals in stores
- Building in the EAA's design standards for products
- Implementing robust processes and controls and training programs
In more detail
The European Accessibility Act (Directive 2019/882) is a landmark law that requires certain products and services in the EU to be accessible to people with disabilities. The EAA sets out specific accessibility requirements that various stakeholders, including manufacturers, authorized representatives, importers, distributors, and service providers, must meet.
Types of services caught by the EAA
The scope of the European Accessibility Act is broad, encompassing a wide range of products and services provided to consumers. These include e-commerce services, electronic communication services (excluding M2M services), and services that provide access to audiovisual media. Additionally, the EAA covers TV equipment, smartphones, desktops, notebooks, tablets, banking services, e-books, and dedicated software. Elements of passenger transport services and self-service terminals are also included under the EAA's requirements.
Exceptions
While the EAA imposes stringent accessibility standards, it does allow for certain exceptions. Stakeholders may be able to rely on the fundamental alteration or disproportionate burden exceptions, provided they conduct a documented assessment to justify these claims. However, we do expect the ability to rely on these exceptions to be relatively limited in practice.
BM Infographic
For more information on this legislation and to see a snapshot of where the provisions have already been implemented, see our infographic here.
For any questions about the EAA, please get in touch with us or your usual Baker McKenzie contacts.
